PensionsEurope welcomes the opportunity to comment on the EBA consultation about its draft Regulatory Technical Standards (RTS) on Initial Margin Model Validation (IMMV) under the European Markets Infrastructure Regulation (EMIR). It is PensionsEurope’s opinion that the suggested RTS regarding the adoption and governance of IM models will introduce new heavy and unjustified burdens on a vast number of counterparties and we believe that the proposed requirements overshoot what’s necessary in order to curb risks to the financial system arising from IM calculations.

We therefore suggest removing the article 2, 2. option or, at least, to provide clearer and more objective criteria for requiring section 3 compliance from counterparties above the EUR 50 billion threshold. You can read our comments here.